The P:irliament in devising a special definition of the expression "dependant" has included therein all . coparceners except the karta. If it be that the definition given in s. 2 (g) is not to apply in interpreting s. 4 of the Act, expenditure incurred for the personal requirements of all the coparceners would have to be excluded. But that is not the contention of the revenue. No rule of interpretation permits for the purpose of s. 4(i) of the Act the application of the statutory definition of "dependant" to bring within the net of taxation, expendiutre incurred for copar-ceners other than the karta, and of a special meaning of that expression inconsistent alike with the personal law of the parties, aµd the statutory definition to bring within the net the expenditure for the karta. The Court cannot attribute two different meanings to a single expression in its application to two different situations contemplated by a single clause. The case "is one clearly of defective draftsmanship. In ss. 5 & 6 wherever it was thought necessary, having regard to the special relation between members of a Hindu undivided family, the Parliament has restricted the use of the expression "dependant" to individual assessees, and has used different phraseology in defining exclusions and deductions in computing the taxable expenditure of assessees : see s. 5 (r); s. 6(c)(ii); s. 6(f)(ii); s. 6(g) ands. 6(h). In s. 4, however, the Parliament has in seeking to attain undue brevity failed to make provision for inclusion in computing the taxable expenditure of a Hindu undivided family expenditure incurred by the kart a out of his separate .estate, which expenditure would have been incurred by the family if it was not incurred by the karta.
